On April 30, RCRC submitted comments to CalRecycle on proposed regulations that seek to increase consumer access to redemption opportunities.   

SB 1013 (Atkins,2022) made significant changes to the state’s beverage container recycling law, including adding wine containers to the program.  SB 1013 also repealed the ability for retailers to pay a $100/day in lieu fee to CalRecycle to avoid having to redeem beverage containers in the store.  Under the new law, beverage container “dealers” must either redeem containers in store or join a dealer cooperative that will redeem containers.  This part of the law was intended to significantly increase consumer access to redemption opportunities while providing “dealers” a way to avoid having to redeem containers in the store. 

CalRecycle released draft regulations for a 45-day comment period on March 15.  RCRC has expressed serious concerns that the proposed regulations may actually increase consumer confusion and frustration as well as decrease consumer participation. 

The proposed regulations require each dealer cooperative to include at least one reverse vending machine, bag drop off, or pickup program, but without the operational requirements that currently exist for similar technologies outside of the dealer cooperative setting.  Even more troubling, the proposed regulations absolve these redemption locations from having to redeem all types of beverage containers.  Under existing law and SB 1013, at least one location in each convenience zone must redeem all empty beverage containers, but the regulations appear to directly conflict with this requirement.  As structured, the draft regulations would allow one location to take only glass containers, another to take only plastic containers, and another to take only metal containers.  Under this framework, consumers may have to visit two or more different redemption locations to redeem all their empty beverage containers. 

The proposed regulations also allow dealer cooperatives to limit the number of containers that an individual may redeem in a single day.  Given the cost of gas and distance consumers must travel to redemption locations, this could erode a consumer’s ability to get any of his or her deposits back. 

RCRC has suggested modifications to address both of these concerns.  SB 1013 and the proposed regulations provide a great opportunity to increase redemption opportunities and facilitate more holistic drop-off recycling programs; however, the details matter. 

For more information, please contact RCRC Senior Policy Advocate, John Kennedy